ML24197A016

NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC - Fleet Request - License Amendment Request to Adopt TSTF-591

ML24197A016
Person / Time
Site:	Calvert Cliffs, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, FitzPatrick, LaSalle
Issue date:	07/12/2024
From:	Scott Wall NRC/NRR/DORL/LPL3
To:	Flickinger S Constellation Energy Generation
Wall S
References
L-2024-LLA-0046
Download: ML24197A016 (6)

Text

From: Scott Wall Sent: Friday, July 12, 2024 5:01 PM To: Flickinger, Stephen F:(Constellation Nuclear)

Cc: Gantt, Danii M:(Constellation Nuclear)

Subject:

FINAL RAI - Constellation Energy Generation, LLC - Fleet Request - License Amendment Request to Adopt TSTF-591 (EPID No. L-2024-LLA-0046)

Dear Steve Flickinger,

By letter dated April 12, 2024 (Agencywide Documents Access and Management System Accession No. ML24103A204), Constellation Energy Generation, LLC (CEG, the licensee) submitted license amendment requests (LAR) for Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Clinton Power Station, Unit 1, James A. FitzPatrick Nuclear Power Plant (FitzPatrick), LaSalle County Station, Units 1 and 2, Limerick Generating Station, Units 1 and 2, Nine Mile Point Nuclear Station, Units 1 (NMP1) and 2 (NMP2), Peach Bottom Atomic Power Station, Units 2 and 3, and R.E. Ginna Nuclear Power Plant (collectively, the facilities).

The proposed amendments requested adoption of Technical Specifications Task Force (TSTF)

Traveler, TSTF-591, Revision 0, Revise Risk Informed Completion Time (RICT) Program.

TSTF-591 revises the Technical Specifications (TS) Section 5.5 Programs and Manuals, Risk Informed Completion Time Program, to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and adds a new report to TS Section 5.6, Reporting Requirements, that informs the U.S. Nuclear Regulatory Commission (NRC) of newly developed methods used to calculate a RICT. Additionally, CEG is requesting the removal of certain units Facility Operating License (FOL) condition sections associated with the implementation of the Title 10 of the Code of Federal Regulations (10 CFR) Section 50.69 and Risk-Informed Completion Time programs.

The NRC staff has reviewed the submittal and determined that additional information is needed to complete its review. The specific question is found in the enclosed request for additional information (RAI). On July 11, 2024, the CEG staff indicated that a response to the RAIs would be provided by August 9, 2024.

If you have questions, please contact me at 301-415-2855 or via e mail at Scott.Wall@nrc.gov.

Scott P. Wall Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301.415.2855 Scott.Wall@nrc.gov

Docket Nos.: STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317, 50-318, 50-461, 50-333, 50-373, 50-374, 50-352, 50-353, 50-220, 50-410, 50-277, 50-278 and 50-244

Enclosure:

Request for Additional Information

cc: Listserv

RAI (TSTF-591)

REQUEST FOR ADDITIONAL INFORMATION

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT

TSTF-591, REVISION 0

CONSTELLATION ENERGY GENERATION, LLC

BRAIDWOOD STATION, UNITS 1 AND 2

BYRON STATION, UNIT NOS. 1 AND 2

CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2

CLINTON POWER STATION, UNIT NO. 1

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3

JAMES A. FITZPATRICK NUCLEAR POWER PLANT

LASALLE COUNTY STATION, UNITS 1 AND 2

LIMERICK GENERATING STATION, UNITS 1 AND 2

NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3

R. E. GINNA NUCLEAR POWER PLANT

DOCKET NOS. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317,

50-318, 50-461, 50-333, 50-373, 50-374, 50-352, 50-353, 50-220, 50-410,

50-277, 50-278 AND50-244

By letter dated April 12, 2024 (Agencywide Documents Access and Management System Accession No. ML24103A204), Constellation Energy Generation, LLC (CEG, the licensee) submitted license amendment requests (LAR) for Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Clinton Power Station, Unit 1, James A. FitzPatrick Nuclear Power Plant (FitzPatrick), LaSalle County Station, Units 1 and 2, Limerick Generating Station, Units 1 and 2, Nine Mile Point Nuclear Station, Units 1 (NMP1) and 2 (NMP2), Peach Bottom Atomic Power Station, Units 2 and 3, and R.E. Ginna Nuclear Power Plant (collectively, the facilities).

The proposed amendments requested adoption of Technical Specifications Task Force (TSTF)

Traveler, TSTF-591, Revision 0, Revise Risk Informed Completion Time (RICT) Program.

TSTF-591 revises the Technical Specifications (TS) Section 5.5 Programs and Manuals, Risk Informed Completion Time Program, to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and adds a new report to TS Section 5.6, Reporting Requirements, that informs the U.S. Nuclear Regulatory Commission (NRC) of newly developed methods used to calculate a RICT. Additionally, CEG is requesting the removal of certain units Facility Operating License (FOL) condition sections associated with the implementation of the Title 10 of the Code of Federal Regulations (10 CFR) Section 50.69 and Risk-Informed Completion Time programs.

The NRC staff has reviewed the submittal and determined that additional information is needed to complete its review.

Technical Specifications Branch (STSB) Questions

Applicable Regulation and Guidance

The regulation under 10 CFR 50.36(b) requires that:

Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; technical information]. The Commission may include such additional technical specifications as the Commission finds appropriate.

The categories of items required to be in the TSs are listed in 10 CFR 50.36(c).

The regulation at 10 CFR 50.36(c)(5), states that administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

NRC RGs provide one way to ensure that the regulation s continue to be met. The NRC staff considered during its review of the proposed changes, along with industry guidance endorsed by the NRC, the guidance in RG 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, December 2020 (ML20238B871).

• NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [light-water reactor] Edition (SRP):

o Chapter 19, Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance, dated June 2007 (ML071700658).

o Chapter 16, Section 16.0, Technical Specifications, March 2010 (ML100351425). The NRC staffs review includes consideration of whether the proposed changes are consistent with the NRC NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21259A155 and ML21259A159, respectively).

o Chapter 16, Section 16.1, Risk-Informed Decision Making: Technical Specifications, March 2007 (ML070380228).

• Nuclear Energy Institute (NEI) 06-09-A, Revision 0, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines (ML063390639),

provides guidance for risk-informed TS. The NRC staff issued a final SE approving NEI 06-09 on May 17, 2007 (ML071200238).

• NEI 17-07, Revision 2, "Performance of PRA Peer Reviews Using the ASME/ANS PRA Standard," provides guidance material for conducting and documenting a probabilistic risk assessment (PRA) peer review using the American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) PRA Standard, issued August 2019 (ML19231A182).

• PWR Owners Group (PWROG) topical report PWROG-19027-NP, Revision 2, "Newly Developed Method Requirements and Peer Review," establishes the definitions, processes, and technical requirements necessary to implement newly developed methods, issued July2020 (ML20213C660). RG 1.200, Revision 3, endorsed specified portions of PWROG-19027-NP.

=

Background===

In Section 2.2, Variations CEG included proposed changes to specific FOLs for the CEG facilities that would remove license conditions associated with the implementation of TSTF-505, 10 CFR 50.69 and instance of RG 1.200, Revision 2 for the 10 CFR 50.69 program.

The licensee asserted these implementation conditions have been implemented, are no longer relevant, and do not affect the applicability of TSTF-591-A. While these implementation conditions may not affect the applicability of TSTF-591 they go beyond the adoption of the traveler. TSTF-591 was developed to be processed and reviewed as a CLIIP (Consolidated Line-Item Improvement Process). For example, the licensee proposes the remova l of license conditions associated with 10 CFR 50.69 program. Furthermore, these implementation conditions are not associated with the proposed removal of the license condition and newly revised paragraph e for the RICT program that TSTF-591 incorporates.

RAI-STSB-01

In Section 2.2, Variations, of the LAR, CEG included proposed changes to specific FOLs for the CEG fleet that would remove license conditions associated with the implementation of TSTF-505, 10 CFR 50.69 and instance of RG 1.200, Revision 2 for the 10 CFR 50.69 program.

CEG proposes to remove the license condition that serves the same purpose as Paragraph e in TSTF-505 because the implementation conditions are no longer relevant.

License Conditions are subject to oversight and inspection. Removal of the license conditions in the subject LAR would therefore need to be validated and verified to assure PRA configuration control is maintained and there is no adverse impact on the decision rendered by the NRC staff for the issued amendment the license condition(s) supported.

The licensee asserted these implementation conditions have been implemented, are no longer relevant, and do not affect the applicability of TSTF-591. While these implementation conditions may not affect the applicability of TSTF-591, they go beyond the adoption of the traveler.

TSTF-591 was developed to be processed and reviewed as a CLIIP. The NRC staff acknowledges the proposed changes in this subject LAR that variated from the TSTF-591 are not major, however, they are not administrative in nature because they do required review to support validation and verification beyond the standard process for review of CLIIPs.

• Per TSTF-591, it states in the model application that the licensee describes the differences between the license condition and the TSTF-505, Revision 2, Paragraph e and why they do not affect the applicability of TSTF-591. Please provide the information to justify how the implementation conditions are no longer relevant.

RAI-STSB-02

The NRC staff noted the following editorial issues in Attachment 2 of the LAR (mark-ups):

FitzPatrick

• For Insert 1, item a., the licensee has the phrase and means of assessing the hazard which is not in the TSTF-591 traveler. Provide justification or correct.

• For Insert 2, first paragraph, the licensee has the phrase prior to using those methods instead of prior to the first use of those methods which is the approved language in the traveler. Provide justification or correct.

NMP1

• For Insert 1, item g. the licensee states A report shall be submitted in accordance with Specification 5.6.9 before a newly developed method is used to calculate a RICT.

Insert 2 references Specification 6.6.8. Provide justification or correct.

Hearing Identifier: NRR_DRMA Email Number: 2552

Mail Envelope Properties (SA1PR09MB96056FB8E3C4812A8A51DCF992A62)

Subject:

FINAL RAI - Constellation Energy Generation, LLC - Fleet Request - License Amendment Request to Adopt TSTF-591 (EPID No. L-2024-LLA-0046)

Sent Date: 7/12/2024 5:00:33 PM Received Date: 7/12/2024 5:00:38 PM From: Scott Wall

Created By: Scott.Wall@nrc.gov

Recipients:

"Gantt, Danii M:(Constellation Nuclear)" <Danii.Gantt@constellation.com>

Tracking Status: None "Flickinger, Stephen F:(Constellation Nuclear)" <Stephen.Flickinger@constellation.com>

Tracking Status: None

Post Office: SA1PR09MB9605.namprd09.prod.outlook.com

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